RECONSIDERATION OF LAAHNC PETITION FAA-2015-5044 – Special Federal Aviation 

Regulation (SFAR) for Los Angeles County Coastal Shore Line Route

Los Angeles Area Helicopter Noise Coalition (LAAHNC) 1 of 5

Los Angeles Area Helicopter Noise Coalition (LAAHNC)

Post Office Box 571448

Tarzana, CA 91357-1448

Please provide all replies and communications regard this matter to:

Richard Root, (310) 375-1594, email: rroot92477@aol.com

June 17, 2016

US Department of Transportation – Document Operations

1200 New Jersey Avenue, SE 

West Building Ground Floor

Room W12-140

Washington, DC 20590

RECONSIDERATION OF LAAHNC PETITION FAA-2015-5044

SPECIAL FEDERAL AVIATION REGULATION (SFAR) FOR LOS ANGELES COUNTY

COASTAL SHORE LINE ROUTE

On May 20, 2016, the Federal Aviation Administration (FAA) notified the Los Angeles Area 

Helicopter Noise Coalition (LAAHNC) that it was dismissing our petition (FAA-2015-5044) to 

establish a helicopter route off the Los Angeles County shoreline. The purpose of this letter is to 

petition the FAA to reconsider its dismissal. 

CFR §11.73 lists the following criteria the FAA considers when evaluating a petition:

1) The immediacy of the safety or security concerns you raise;

2) The priority of other issues the FAA must deal with; and

3) The resources we have available to address these issues.

The FAA dismissal letter states, “After reviewing your request based on the current priorities for the 

FAA and the guidelines found in §11.73, we determined the issue you raised does not meet the criteria 

to pursue rulemaking at this time.” There is no discussion as to what the FAA’s “current priorities” are 

or where the issue of helicopter noise stands on the priority list. There is also no mention of lack of 

resources. But, it seems the main reason for the dismissal is that the FAA does not consider the issue of 

reducing helicopter noise in the Los Angeles County to be a high priority. 

Under 14 CFR § 11.101, for the FAA to accept this petition for reconsideration, we must show the 

following: 

(a) That we have a significant additional fact and why we did not present it in our original petition;

(b) That the FAA made an important factual error in its denial of our original petition; or

(c) That the FAA did not correctly interpret a law, regulation, or precedent.

The FAA has very narrow grounds for accepting a request for reconsideration and they do not allow us 

to question its priorities. However, at the end of its four page letter the FAA also states that, “For the 

reasons above, we are dismissing your petition for rulemaking in accordance with 14 CFR §11.73. The 

“reasons above” include a number of statements that seem to relate to the merits of our petition. 

Accordingly, we submit the following comments in support of our request for reconsideration. These 

comments consist of significant additional facts and factual errors, including misstatements and 

omissions of important facts.
RECONSIDERATION OF LAAHNC PETITION FAA-2015-5044 – Special Federal Aviation 

Regulation (SFAR) for Los Angeles County Coastal Shore Line Route

Los Angeles Area Helicopter Noise Coalition (LAAHNC) 2 of 5

Significant Additional Facts

At the time we submitted our original petition on October 20, 2015, we were not aware that the FAA’s 

flight data analysis for the Palos Verdes Low and High Regions of Interest was not accurate. 

Subsequently, we became aware that the analysis significantly underrepresented the concentration of 

helicopter flights on the coastline in these regions. It appears that the FAA misidentified more than half 

of the helicopter flights as fixed wing planes. We brought this to the FAA’s attention on May 2, 2016, 

and requested it review the analysis, but we have not received any explanation. We also submitted a 

comment on Regulations.gov explaining this issue. However, since it is not addressed in the FAA’s 

dismissal letter, we do not know whether it was considered. In any event, the volume of helicopter 

flights in this area is much greater than was known at the time we submitted our original petition. The 

heavier concentration of helicopter flights is compelling evidence of significant noise impacts on these 

coastal communities and it should be taken into account.

Factual Errors

Listed below are statements taken directly from the FAA’s dismissal letter followed by LAAHNC 

comments (in italics).

Geographic, Topographic and Climate Limitations

“The geography that Los Angeles County encompasses is as diverse as the population. There are 

1,875 square miles of mountains, with the highest point located 10,080 feet above sea level atop Mt. 

San Antonio, and 1,741 square miles of flatland that includes a low point of nine feet below sea level 

in the City of Wilmington. The difference in elevation between the Los Angeles Civic Center and the 

surrounding mountains is greater than between the City of Denver and its surrounding mountains. 

Additionally, Los Angeles County includes 75 miles of mainland coastline, plus an additional 

129 square miles of islands.”

LAAHNC Comment: The FAA provided no explanation as to how these features “limit” the creation of 

an offshore route. In fact, none of them do so. The shoreline route we proposed is entirely over the 

ocean, not over any mountains. 

“Los Angeles experiences two main and unique weather patterns: ‘June Gloom’ and ‘the Santa Ana 

winds.’ The first refers to the ocean fog that keeps the beach cities (and often all of the Los Angeles 

Basin) overcast into early afternoon and most common in June, but can occur any time between March 

and mid-August. The middle of autumn (October-November) often brings the Santa Ana winds, strong, 

hot winds from across the desert that increase brush-fire danger and reverse the prevailing offshore 

winds. Topography and climate conditions play an important role in a pilot's decision whether to fly 

and what routes to use, especially during the hazy days during the ‘June Gloom.’ Reduced visibility 

and lower cloud ceilings force visual flight rules (VFR) helicopters to fly at lower altitudes.”

LAAHNC Comment: This paragraph contains several errors. Obviously, pilots should not fly VFR in 

low clouds when they cannot see. Under such conditions they should not fly along the coastline at all. 

Instead they should choose other routes. “June Gloom” does not preclude the creation of an offshore 

route to be used when weather conditions do permit, which is the vast majority of the time. Also, the 

phrase “prevailing offshore winds” is factually incorrect. In fact, the prevailing winds are onshore, 

not offshore. Moreover, offshore Santa Ana winds do not occur “often.” According to a study done by 

the University of California, Los Angeles, Santa Ana winds average only 20 times per year with an 

average duration of 1.5 days and they are also spread over a longer time period (September-April).

(Source: The Santa Ana Winds of California by M. N. Raphael, Department of Geography, University 
RECONSIDERATION OF LAAHNC PETITION FAA-2015-5044 – Special Federal Aviation 

Regulation (SFAR) for Los Angeles County Coastal Shore Line Route

Los Angeles Area Helicopter Noise Coalition (LAAHNC) 3 of 5

of California, Los Angeles, Los Angeles, California). In addition, Santa Ana winds affect the entire Los 

Angeles basin with the strongest winds near mountain passes, not the shoreline. If the Santa Ana winds 

are too strong to fly near the shoreline, they are most likely too strong to fly throughout the Los 

Angeles area. The fact that there are occasional Santa Ana winds does not preclude the creation of an 

offshore route. Finally, our proposed regulation included a provision that stated pilots may deviate 

from the routes when necessary for safety and weather conditions. These atypical weather conditions 

do not preclude establishment of a route that could be used the vast majority of the time, just as these 

conditions do not prevent the FAA from developing a “voluntary” route. Whether the route is 

mandatory or voluntary, exceptions would have to be made for weather conditions. 

“The FAA found the majority of the shoreline operations are conducted by single engine helicopters 

which are not equipped with float devices. Pilots maintain close proximity to the shoreline in order to 

safety [sic] conduct an autorotation in the event of emergency.” 

LAAHNC Comment: The dismissal letter did not address our concern about putting the safety of the 

public on the ground at risk. Instead of attempting emergency landings on densely populated shores, 

helicopters that fly along the shoreline should be equipped with flotation devices so they can safely 

land in the ocean. The letter also fails to mention that the largest percentage of helicopters that fly 

along on the shorelines of Palos Verdes peninsula and the South Bay are Robinson Helicopter 

Company test flights. Unlike helicopters carrying passengers for hire, these test flights are not 

required to fly close to shore. Instead, Robinson’s FAA permit requires them to conduct test flights in a 

large designated area over the Pacific Ocean, which extends from the shoreline up to two miles 

offshore, from Manhattan Beach to Long Beach. Therefore, these test flights should be flown farther 

offshore instead of on the shoreline. Moreover, whenever they follow the coastline, they certainly can 

and should use the route we proposed to be one mile offshore, still well within their designated test 

flight area. 

“The lateral distance a helicopter is capable of maneuvering during an autorotation is different for each 

aircraft type. Placing a mandatory distance offshore for helicopter operations would require an increase 

in altitude in order for the pilot to safely conduct an autorotation.” 

LAAHNC Comment: This is a true statement, but it does not rule out the creation of an offshore route. 

The specific glide ratios of most helicopters used this area range from 4:1 to 5.5:1. The minimum glide 

ratio of 4:1 means that a helicopter can glide four feet laterally for every foot of altitude. So, a 

helicopter flying at an altitude of 1,500 feet can glide without power over 6,000 feet laterally (over a 

mile). The factual data indicate that a lateral distance offshore could be established that virtually all 

helicopters in use in this area would be capable of gliding from a reasonable altitude. The fact that the 

pilot has the discretion to fly as high as needed is not a limitation, as implied by the dismissal letter. 

Instead, it provides flexibility for pilots to comply with the route. Finally, the FAA fails to mention that 

our proposed regulation provided for exceptions in the rare event that safety would not allow a pilot to 

fly high enough and the distance offshore exceeded a helicopter’s glide capability. 

“The volume and complexity of fixed wing aircraft in Los Angeles County transitioning in various 

stages of flight (approach, departure, enroute) prohibits helicopters from flying at higher altitudes.” 

LAAHNC Comment: This statement is incorrect. There is no regulation that “prohibits” helicopters 

from flying higher along the County’s 75-mile coastline, except when necessary to comply with Air 

Traffic Control direction at the shoreline west of LAX, for a distance of about 2 miles. So, helicopter 

altitudes along nearly the entire coastline are flown at the pilot’s discretion and they occasionally fly 

at and above 2,000 feet, which demonstrates that it can be done. 
RECONSIDERATION OF LAAHNC PETITION FAA-2015-5044 – Special Federal Aviation 

Regulation (SFAR) for Los Angeles County Coastal Shore Line Route

Los Angeles Area Helicopter Noise Coalition (LAAHNC) 4 of 5

“In collaboration with stakeholders, the FAA has developed a voluntary offshore route in the greater 

Los Angeles County area that encourages and allows the safe operation of helicopters at a prescribed 

distance offshore. A safety review has been completed on the route and an environmental review is 

underway.”

LAAHNC Comment: This statement implies that LAAHNC collaborated on the development of the 

voluntary offshore route. It mischaracterizes the facts. LAAHNC is the only stakeholder group 

representing the impacted public. Yet, we never had a chance to “collaborate” on the development of 

this route. During the course of our meetings with the FAA and pilots, the FAA unilaterally developed 

voluntary offshore route concepts and presented them to the stakeholders. The last presentation we 

attended was on June 11, 2015, and at that time the FAA proposed a route one-quarter mile offshore. 

Later, we learned that, after that meeting, the FAA continued to meet with pilots on the development of 

the route. But, we were given no notice or opportunity to participate in those meetings. We were also 

not given any notice or opportunity to participate in or observe the safety or environmental reviews. 

Now, we are only being told that a route has been developed. The prescribed distance offshore has still 

not been disclosed to us. Recently, we heard unofficially that this route would be much closer to shore 

than one-quarter mile. If true, the route has been changed from the route last presented to us. Based 

on these facts, it is inaccurate to state that an offshore route was developed “in collaboration with 

stakeholders.”

Whether the offshore route is voluntary or mandatory, the most important factor is its distance 

offshore. Without the route being defined it is impossible for anyone to assess whether or not it would 

be effective in reducing noise. The dismissal letter did not mention that the FAA’s flight data analysis 

showed that helicopters currently average about one-quarter mile offshore of the Torrance and Palos 

Verdes peninsula shorelines, even though no offshore route currently exists. To achieve a significant 

reduction in noise, the route would have to be farther offshore than one-quarter mile. A route onequarter mile offshore is similar to the current practice, so it would not significantly reduce overall 

noise. But, at least it might help get more helicopters to avoid flying directly above shorelines and 

beaches. On that basis, LAAHNC might be willing to support trying such a voluntary route (only for 

those helicopters required to fly close to shore) as a first step while evaluating its effectiveness. 

However, if the route is less than one-quarter mile offshore, it would increase noise and be 

counterproductive.

“The FAA and the stakeholder working groups have made significant progress on each of the six 

actions specified in the 2014 Consolidated Appropriations Act, Public Law No. 113-76 (January 3, 

2014).” 

LAAHNC Comment: Under any objective reading of the Act, significant progress has not been made. 

The Act stated, “The Secretary shall (1) evaluate and adjust existing helicopter routes above Los 

Angeles, and make adjustments to such routes if the adjustments would lessen impacts on residential 

areas and noise-sensitive landmarks ...” Under the Act, significant progress on this action was to have 

been made by January, 2015. Now, almost a year and one-half after the deadline for progress, no 

routes or altitudes have been adjusted and no actual reduction in helicopter noise has been achieved. 

“With this foundation, the FAA and stakeholders have made progress in identifying route adjustments 

that could lessen impacts on residential areas and noise-sensitive landmarks while avoiding shifting 

noise from one residential neighborhood to another.”

LAAHNC Comment: This statement is incorrect. As participating stakeholders, we are not aware of 

any progress in identifying routes in Los Angeles County for “adjustment”. The only route under 
RECONSIDERATION OF LAAHNC PETITION FAA-2015-5044 – Special Federal Aviation 

Regulation (SFAR) for Los Angeles County Coastal Shore Line Route

Los Angeles Area Helicopter Noise Coalition (LAAHNC) 5 of 5

consideration that has the potential to lessen impacts without shifting noise from one residential area 

to another is the creation of a new offshore route. But, until the offshore route is defined, an evaluation 

cannot be made as to whether it would actually reduce noise.

The foregoing constitutes the summary that may be published in the FEDERAL REGISTER as 

provided under Subpart B. 

Executed at Torrance, California on June 17, 2016.

Richard Root, Vice President

Los Angeles Area Helicopter Noise Coalition (LAAHNC)